Cases
Glatt v. Canada (National Revenue), 2019 FC 738
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|---|---|---|
| Tax Topics - Income Tax Act - Section 164 - Subsection 164(3) | naming of a taxation year respecting a reassessment cancelling a s. 163.2 penalty was not an “error” that precluded the payment of refund interest | 537 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | CRA could not treat its statement of a taxation year in its Notice of Reassessment as an error | 367 |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 18.1 - Subsection 18.1(2) | extension granted where the taxpayer had continually pursued relief | 387 |
Sarmadi v. Canada, 2017 FCA 131
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Vine Estate v. Canada, 2015 DTC 5063 [at 5880], 2015 FCA 125
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | filing amended return does not nullify previous lack of reasonable care/quaere whether neglect can be vicarious though outside accountants | 528 |
Swirsky v. Canada, 2014 DTC 5037 [at 6723], 2014 FCA 36, aff'g 2013 TCC 73, 2013 DTC 1078 [at 431]
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | no objectively reasonable expectation of taxable dividends | 433 |
| Tax Topics - General Concepts - Purpose/Intention | no objectively reasonable income-producing purpose | 83 |
Palmerino v. Canada (National Revenue), 2013 FC 919
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| Tax Topics - Other Legislation/Constitution - Federal - Privacy Act - Paragraph 22(1)(a) | onus on CRA to prove communications were part of criminal investigation | 66 |
Newmont Canada Corporation v. Canada, 2012 DTC 5138 [at 7292], 2012 FCA 214
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | 99 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | loan made as investment in mining business | 162 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | interest was bad as settlement proceeds not allocated to it | 212 |
House v. Canada, 2011 DTC 5142 [at 6131], 2011 FCA 234
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| Tax Topics - General Concepts - Evidence | credible oral evidence can be uncorroborated by documents | 90 |
Khan v. The Queen, 2009 DTC 804, 2009 TCC 248 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 169 - Subsection 169(1) | 34 |
Canada v. Anchor Pointe Energy Ltd., 2007 DTC 5379, 2007 FCA 188
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Words and Phrases
assessmentTransocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) | damages to lessor for advance lease repudiation were in lieu of rent | 298 |
Canada v. Loewen, 2004 DTC 6321, 2004 FCA 146
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | 92 |
Canada v. Anchor Pointe Energy Ltd., 2003 DTC 5512, 2003 FCA 294
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|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(5) | objection does not extend normal reassessment period | 240 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | 152 | |
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(5) | 240 |
Capital Vision Inc. v. MNR, 2003 DTC 5054 (FCTD)
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| Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(1) | 158 |
Roseland Farms Ltd. v. Canada, 2001 DTC 5392, 2001 FCA 167
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Cardella c. Canada, 2001 DTC 5251, 2001 FCA 39
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | 83 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 104 |
C W Agencies Inc v. The Queen, 2000 DTC 2372 (TCC), aff'd 2002 DTC 6740, 2001 FCA 393
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Scientific Research & Experimental Development | 82 |
Coffen v. The Queen, 97 DTC 5552 (Ont. Ct. J. (G.D.))
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| Tax Topics - Income Tax Act - Section 150 - Subsection 150(1) | 28 | |
| Tax Topics - Income Tax Act - Section 239 - Subsection 239(1) - Paragraph 239(1)(d) | 94 |
Canderel Ltd. v. Canada, 98 DTC 6100, [1998] 1 S.C.R. 147
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | 55 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 151 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | lease inducement payments currently deductible | 117 |
Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336
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Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | 107 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) | interest-free advances to US sub by developer | 33 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | interest-free advances made only re loss protection | 47 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 200 |
CPL Holdings Ltd. v. The Queen, 95 DTC 5253 (FCTD)
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| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) | s. 55(2) did not apply as purpose was creditor-proofing | 153 |
Québec (Communauté urbaine) v. Corp. Notre-Dame de Bon-Secours, 95 DTC 5017, [1994] 3 S.C.R. 3
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| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 167 |
W. Hanley & Co. Ltd. v. The Queen, 90 DTC 6354 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 131 |
First Fund Genesis Corp. v. The Queen, 90 DTC 6337 (FCTD)
Youngman v. The Queen, 90 DTC 6322 (FCA)
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | benefit reduced by interest-free loan made by shareholder | 259 |
The Queen v. Mattabi Mines Ltd., 89 DTC 5357 (FCTD), aff'd 92 DTC 6252 (FCA)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(gg) | 75 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory | 75 |
Grohne v. The Queen, 89 DTC 5220 (FCTD)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | mere fulfillment of contractual obligation | 144 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Employee | 30 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(5) | 145 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | 62 |
Smith, Kline & French Laboratories Ltd. v. A.G. (Can.), 89 DTC 5205 (FCTD)
Interprovincial Co-operative Ltd. v. The Queen, 87 DTC 5115, [1987] 1 CTC 222 (FCTD)
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| Tax Topics - Income Tax Act - Section 135 - Subsection 135(4) - Income of the Taxpayer Attributable to Business Done With Members | 51 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | property acquired only because parent so directed | 90 |
Wise v. The Queen, 86 DTC 6023, [1986] 1 CTC 169 (FCA)
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| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | deposit | 61 |
The Queen v. Bassani, 85 DTC 5232, [1985] 1 CTC 314 (FCTD)
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 195 |
Tony Mele Incorporated v. The Queen, 85 DTC 5196, [1985] 1 CTC 252 (FCTD)
Krassman v. The Queen (1979), 102 D.L.R. (3d) 262 (FCTD)
Farmer Construction Ltd. v. The Queen, 83 DTC 5215, [1983] CTC 198 (FCTD)
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| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Subparagraph 46(1)(a)(v) | 71 |
Hillsdale Shopping Centre Ltd. v. The Queen, 81 DTC 5261, [1981] CTC 322 (FCA)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | 55 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Options | 86 |
Kit-Win Holdings (1973) Ltd. v. The Queen, 81 DTC 5030, [1981] CTC 43 (FCTD)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - General Concepts - Purpose/Intention | 39 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | 77 |
The Queen v. Farmparts Distributing Ltd., 80 DTC 6157, [1980] CTC 205 (FCA)
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | right to buy and resell product not a right to use | 200 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) | lump sum paid irrespective of user not "royalty" | 137 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 11 | |
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | "including" enlarges | 99 |
Simpson v. The Queen, 79 DTC 5336 (FCTD)
Tobias v. The Queen, 78 DTC 6028, [1978] CTC 113 (FCTD)
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Quality Chekd Dairy Products Association v. MNR, 67 DTC 5303 (Ex Ct)
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 167 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | 130 |
See Also
Lohas Farm Inc. v. The Queen, 2019 TCC 197
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | buyers made purchases of iPhones as agents for a grey market reseller | 407 |
| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 3 - Paragraph 3(c) - Subparagraph 3(c)(ii) | missing names in receipts issued by vendor were cured by memo maintained by the purchaser | 199 |
| Tax Topics - Excise Tax Act - Section 169 | purchases were made as agent for grey market registrant | 260 |
Monsell v. The Queen, 2019 TCC 5 (Informal Procedure)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | CRA has the onus of substantiating assessments underlying s. 160 assessments where it had superior records access | 300 |
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(3) - Paragraph 125(3)(b) | SBD denied because no agreement made | 92 |
Morrison v. The Queen, 2018 TCC 220
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| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | gift was not vitiated by benefits | 518 |
| Tax Topics - General Concepts - Fair Market Value - Other | Ontario list price of generic pharmaceuticals substantially exceeded their FMV in the international market | 201 |
Agence du revenu du Québec v. Stamatopoulos, 2018 QCCA 474
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| Tax Topics - Excise Tax Act - Regulations - Input Tax Credit Information (GST/HST) Regulations - Section 2 - Intermediary | ARQ failed to establish that a named supplier to the taxpayer did not act as a supplier or intermediary | 422 |
| Tax Topics - Excise Tax Act - Section 169 - Subsection 169(4) | burden shifted to ARQ once taxpayer showed that it had business dealings with suppliers named in invoices | 246 |
Custodio v. The Queen, 2018 CCI 47
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| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(2) - Paragraph 227.1(2)(a) | failure of Crown to tender documents proving the unsatisfied-execution requirement | 285 |
Pellerin v. Agence du revenu du Québec, 2017 QCCA 1339
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | statement of onus embedded in s. 152(8) | 75 |
Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197
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| Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) | offshore hedge fund investments were chosen in the main for commercial reasons (e.g., manager reputation), so that s. 94.1 did not apply | 345 |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | Minister's statement was false | 120 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 145 - Subsection 145(3) | expert's report did not include all the underlying data | 109 |
Szymczyk v. The Queen, 2014 TCC 380 (Informal Procedure)
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|---|---|---|
| Tax Topics - General Concepts - Estoppel | Minister's authorization should not be set aside too readily as being contrary to law | 317 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) | late designation not permitted/rule-of-thumb method invalidated by s. 6(1)(k) | 189 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) | separate personal use kilometers required for each vehicle used in year | 169 |
0742443 B.C. Ltd. v. The Queen, 2014 DTC 1208 [at 3811], 2014 TCC 301, aff'd 2015 DTC 5115 [at 6304], 2015 FCA 231
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| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business | storage charges were property income, cf. hotel revenue | 243 |
Bekesinski v. The Queen, 2014 DTC 3604 [at 1169], 2014 TCC 245
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| Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(4) | appellant, who likely backdated resignation, was plausible enough to demolish assumptions | 94 |
Health Quest Inc v. The Queen, 2014 TCC 211 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part II - 24.1 | insufficient product design evidence | 185 |
Galachiuk v. The Queen, 2014 DTC 1153 [at 3494], 2014 TCC 188
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(1) | due diligence is available for the first relevant year, not only the second | 242 |
Drouin v. The Queen, 2014 DTC 1016 [at 2564], 2013 TCC 139
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| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | arrangement looking like Barbados tax shelter was in fact genuine business | 118 |
Dr. Mike Orth Inc. v. The Queen, 2013 DTC 1110 [at 588], 2013 TCC 123 (Informal Procedure)
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Poulin v. The Queen, 2013 DTC 1102 [at 545], 2013 TCC 104
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| Tax Topics - Income Tax Act - Section 244 - Subsection 244(10) | 149 |
Mignardi v. The Queen, [2013] GSTC 39, 2013 TCC 67 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 323 - Subsection 323(1) | onus on Minister where taxpayer had no financial involvement | 114 |
| Tax Topics - Excise Tax Act - Section 323 - Subsection 323(3) | failure to monitor other director | 71 |
| Tax Topics - Excise Tax Act - Section 323 - Subsection 323(5) | no constructive resignation | 63 |
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | onus on Minister where taxpayer had no financial involvement | 114 |
Pawlak v. The Queen, 2012 TCC 355 (Informal Procedure)
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| Tax Topics - Excise Tax Act - Section 296 - Subsection 296(2) | 172 |
Basi v. The Queen, 2012 DTC 1282 [at 3836], 2012 TCC 345
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Brewster v. The Queen, 2012 DTC 1178 [at 3451], 2012 TCC 187 (Informal Procedure)
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SoftSim Technologies Inc. v. The Queen, 2012 DTC 1187 [at 3473], 2012 TCC 181
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | consent of counsel binding | 96 |
| Tax Topics - Income Tax Act - Section 169 | 112 | |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | 48 | |
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 113 |
Marshall v. The Queen, 2012 DTC 1068 [at 2815], 2012 TCC 21
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| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | not liable for amounts paid as agent | 142 |
Szollosi Bens v. The Queen, 2011 TCC 240
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| Tax Topics - Excise Tax Act - Section 285.1 - Subsection 285.1(16) | 93 | |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(3) | 93 |
Rail v. The Queen, 2011 DTC 1190 [at 1057], 2011 TCC 130
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Richard A. Kanan Corporation v. The Queen, 2011 DTC 1168 [at 928], 2011 TCC 211 (Informal Procedure)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege | 287 |
Blais v. The Queen, 2011 DTC 1008 [at 55], 2010 TCC 195 (Informal Procedure)
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| Tax Topics - Income Tax Act - Section 96 | partnership cannot deduct salary paid to a partner | 53 |
Husky Oil Limited v. Canada, 2010 DTC 5089 [at 6887], 2010 FCA 125
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| Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) | 184 | |
| Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) | 178 | |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | 184 |
4528957 Manitoba Ltd. c. M.R.N., 2009 DTC 1218, 2009 TCC 298
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Douthwright v. The Queen, 2007 DTC 1614, 2007 TCC 560 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) | 314 |
Parker Brothers Textile Mills Limited v. The Queen, 2007 DTC 610, 2007 TCC 74
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(dd) | 117 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 54 |
Cloverdale Paint Inc. v. The Queen, 2007 DTC 243, 2006 TCC 628
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l) | 125 |
Hawa v. The Queen, 2007 DTC 28, 2006 TCC 612 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | frequent stock trading | 52 |
Anchor Pointe Energy Ltd v. The Queen, 2006 DTC 3365, 2006 TCC 424
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Crystal Beach Park Limited v. The Queen, 2006 DTC 2845, 2006 TCC 183
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 11 - Paragraph 11(5)(a) | 216 |
Arnold v. The Queen, 2005 DTC 1699, 2005 TCC 725 (Informal Procedure)
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Orly Automobiles Inc. v. Canada, 2005 FCA 425
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Borys v. The Queen, 2005 DTC 1069, 2005 TCC 397
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | 104 | |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) | 104 |
Morley v. The Queen, 2004 DTC 2604, 2004 TCC 280, briefly aff'd 2006 DTC 6351, 2006 FCA 171
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Charter (Constitution Act, 1982) - Section 8 | 36 | |
| Tax Topics - General Concepts - Evidence | 30 | |
| Tax Topics - General Concepts - Fair Market Value - Other | 96 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | 175 | |
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) - Paragraph 13(27)(d) | 86 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | non-arm's length terms | 107 |
| Tax Topics - Income Tax Act - Section 96 | start-up activities sufficient to constitute carrying on business in common | 110 |
Holm v. The Queen, 2003 DTC 755 (TCC)
Molson Brewery BC Ltd. v. Canada, [2002] FCJ No. 87 (FCTD)
Shaughnessy v. The Queen, 2002 DTC 1272 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) | 92 | |
| Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit | 93 |
Weisz Rocchi & Scholes v. The Queen, [2001] 2 CTC 2520, 2001 DTC 3705 (TCC)
Hallatt v. The Queen, 2001 DTC 128 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Other | 14 |
Bell v. The Queen, 97 DTC 484 (TCC)
Bowens v. The Queen, 94 DTC 1853 (TCC), aff'd 96 DTC 6128 (FCA)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 183 |
Graham v. The Queen, 92 DTC 1012 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 169 | 143 | |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(10) | 61 |
Brad-Lea Meadows Ltd. v. MNR, 90 DTC 1269 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) | 143 |